5. Are forgivable loans considered eligible Financial Products?

Yes. There are two instances where forgivable loans can be considered as eligible Financial Products and can be counted for Target Market activity.

The first instance is a forgivable loan with at least one payment within twelve (12) months of the loan closing date.

The second instance is a forgivable loan that meets each of the following seven (7) conditions: 

7. How does the CDFI Fund evaluate the collective financing activity of all entities subject to the collective review process for the CDFI Certification Target Market requirements?

DIHCs, Affiliates of DIHCs, and Subsidiaries of IDIs are subject to the Collective Review process for CDFI Certification. This means that during the CDFI Certification application review process the CDFI Fund will review (1) the individual activities of the Applicant and (2) the activities of the Applicant’s Affiliates to make sure that the Applicant and its Affiliates all meet the requirements for CDFI Certification.

8. How do entities subject to the collective review process meet the CDFI Certification Accountability requirements?

To meet the Accountability test when subject to the CDFI Certification Collective Review process, each Applicant must demonstrate Accountability to its identified Target Market through a governing board or advisory board. In addition, each Affiliate must demonstrate Accountability to its own Collective Review Market components through its own governing board or advisory board—even if an Affiliate’s Collective Review Market type(s) is the same as the Applicant’s proposed CDFI Certification Target Market.

10. How should an Applicant demonstrate that an Affiliate’s¹ sole line of business is the administration of another federal financing program(s)?

Applicants are required only to attest in question BI-A06 whether or not an Affiliate's sole line of business is the administration of another federal financing program(s) (e.g., the SBA 7(A) loan program) and, if the answer is yes, then identify the program.

11. Under what circumstances would an organization need to create an eligible spin-off entity for the purposes of Certification?

An organization may choose to create a spin-off entity for the purposes of Certification when the organization’s predominant activity is non-financing or non-eligible financing and the organization is therefore unable to meet the Financing Entity criterion for Certification. To be eligible for Certification, the newly created entity (i.e., the spin-off entity):

12. Does an Applicant need to fully register with SAM.gov to apply for CDFI Certification or is just obtaining a Unique Entity Identifier (UEI) sufficient?

Yes. An organization applying for CDFI Certification must fully register with SAM.gov. Simply obtaining the UEI without fully registering with SAM.gov is not sufficient. Additionally, once certified, a CDFI must continue to demonstrate that it maintains an active SAM.gov account. A lapse in the SAM.gov account may result in loss of certification as maintaining an active SAM.gov account is required to meet the Legal Entity requirement for Certification.

13. How must an Applicant demonstrate a Primary Mission of promoting Community Development?

In determining whether an entity has a primary mission of promoting community development, the CDFI Fund will consider whether the activities of the Applicant (and of certain Affiliates, including those subject to the CDFI Certification collective review process for Depository Institution Holding Companies (DIHCs), Affiliates of DIHCs, and Subsidiaries of Insured Depository Institutions (IDIs)) are, per regulation,2 purposefully directed toward improving the social and/or economic conditions of underserved people3 and/or residents of economically distressed communities

14. Do the Affiliates of an Applicant need to meet the Primary Mission test?

Yes, any Affiliate that Controls the Applicant (except if the Controlling entity is a Tribal Government) or engages in the provision of Financial Products and/or in Financial Services, including those subject to the CDFI Certification collective review process, must each individually meet the following primary mission requirements: